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Li v. Ernest Orlando Lawrence Berkeley National Laboratory6/30/2004
ring a number of important societal and governmental interests, including: (1) bolstering administrative autonomy; (2) permitting the agency to resolve factual issues, apply its expertise and exercise statutorily delegated remedies; (3) mitigating damages; and (4) promoting judicial economy. The doctrine applies when the entity whose "quasi-judicial" determination is challenged has provided an internal remedy. The reason for the exhaustion requirement in this context is that, as a matter of policy, the entity itself should in the first instance pass on the merits of an individual's application rather than shift this burden to the courts. For courts to undertake the task " `routinely in every such case constitutes both an intrusion into the internal affairs of [the entity] and an unwise burden on judicial administration of the courts.' " (Rojo v. Kliger (1990) 52 Cal.3d 65, 86; accord, Schifando v. City of Los Angeles (2003) 31 Cal.4th 1074, 1091-1092.)
Defendants provided an internal remedy for claims such as those made by plaintiff. Plaintiff, accordingly, properly filed an administrative grievance with defendants. After a full hearing on the matter, her grievance was denied. Plaintiff was entitled to, but did not, seek judicial review of the decision to deny her grievance by filing a petition for writ of mandamus in the superior court pursuant to Code of Civil Procedure section 1094.5.
Two consequences flow from plaintiff's failure to seek judicial review of the administrative proceedings. First, she has lost the right to complain that the proceedings were flawed or that the evidence adduced in them does not support the committee's findings. In short, she has lost the right to review the validity of the administrative proceedings. Second, the decision rendered in those proceedings has become final-a point that raises the doctrine of exhaustion of judicial remedies.
The Supreme Court, in Johnson v. City of Loma Linda (2000) 24 Cal.4th 61, explained: " nless a party to a quasi-judicial proceeding challenges the agency's adverse findings made in that proceeding, by means of a mandate action in the superior court, those findings are binding in later civil actions. This requirement of exhaustion of judicial remedies is to be distinguished from the requirement of exhaustion of administrative remedies. [Citation.] Exhaustion of administrative remedies is `a jurisdictional prerequisite to resort to the courts.' [Citation.] Exhaustion of judicial remedies, on the other hand, is necessary to avoid giving binding `effect to the administrative agency's decision, because that decision has achieved finality due to the aggrieved party's failure to pursue the exclusive judicial remedy for reviewing administrative action.' " (Id. at p. 69-70.)
" `The underpinnings of this rule of exhaustion of judicial remedies . . . are buried in the doctrine of res judicata or that portion of it known as collateral estoppel and more recently as issue preclusion.' [Citation.] `Res judicata . . . deals with the preclusive effects of judgments in civil proceedings. . . . In its primary aspect the doctrine operates as a bar to the maintenance of a second suit between the same parties on the same cause of action. Its secondary aspect comes into play in situations involving a suit, not necessarily between the same parties, based upon a different cause of action. . . . The doctrine of collateral estoppel bars the relitigating of issues which were previously resolved in an administrative hearing by an agency acting in a judicial capacity. [Citation.]' [Citation.]" (Risam v. County of Los Angeles (2002) 99 Cal.App.4th 412, 419-420.) "Issue preclusion is not limited to barring relitigation of court findings. It
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